Healthy Indoors Magazine
Issue link: https://hi.healthyindoors.com/i/1159916
Healthy Indoors | 17 January of 20204. With the EPA also lowering some values that the agency regulates only seems to be muddying the waters further. Also, another very important point to know, the planned EPA and current HUD specific levels are so low on floors that there is the potential to affect the ability of an accredited laboratory to report meeting method and labo- ratory accreditation requirements in some circumstances. Let's dissect all of this a bit and hopefully get everyone on the same page. To set this up, here are the current LBP clearance and risk assessment levels for most LBP work currently: HUD & EPA Lead Dust Clearance Levels (wipe samples) [40 CFR Part 745.227(8)(viii)]1 • ≤40 μg/ft2 floors (carpeted and uncarpeted) • ≤250 μg/ft2 interior window sills • ≤400 μg/ft2 window troughs State/Local program rules may be more stringent. Gen- erally these wipe samples are obtained as 'single sur- face wipes' not composited wipes from multiple surfaces. Composites are discouraged by HUD5 and disallowed in some State/Local rules. If composite samples are de- sired and obtained, they must be analyzed by a lab ac- credited by the National Lead Laboratory Accreditation Program (NLLAP) to analyze composite samples. There are only four labs nationwide that maintain composite wipe accreditation via AIHA/NLLAP. Composite samples are also evaluated differently than singles surface wipes. See the regulation link at footnote 1 and then line (vii). EPA Identification of Lead Hazards; Surfaces & Soil (also used by HUD for most current grant activity; see footnote 1, Subpart D at §745.65) • ≥40 μg/ft2 floors (carpeted and uncarpeted) [wipe sam- ple] • ≥250 μg/ft2 interior window sills [wipe sample] • ≥1,200 ppm building perimeter and yard [soil sample] • ≥400 ppm play areas and high-contact areas for chil- dren [soil sample] Soil: replacement soil < 400 ppm or equal to local "back- ground" level. Many of the same comments apply here as found above for clearance. The reader should see footnote 1 at §745.227(d) Risk Assessment for specific guidance on sampling, data evaluation etc. If performing Lead Risk Assessment, the document found at footnote 5 known as 'the HUD Guidelines,' see Chapter 5 for document- ed methodologies and data evaluation requirements that apply to HUD/federally funded work. The procedures in Chapter 5 are considered to be 'documented methodolo- gies' by the EPA and generally used for all regulated LBP risk assessment work. These values have been a part of the LBP control indus- try lexicon since 2001 and have been dutifully described as part of certified LBP training programs for many years. As such, change is always disruptive, and the values we use for risk assessment and clearance evaluation have and are changing. First, let's start with the HUD issues. HUD issued a document on February 16, 2017; Policy Guidance Number 2017-01 Rev 1, Revised Dust-Lead Action Levels for Risk Assessment and Clearance; Clearance of Porch Floors.3 (hereinafter: "2017-01 Rev 1")…from that document: Applicability: All Lead-Based Paint Hazard Control (LB- PHC) and Lead Hazard Reduction (LHRD) Demonstration Grantees Further from 2017-01 Rev 1: " Effective April 1, 2017, all existing OLHCHH LBPHC and LHRD grantees will use the following dust-lead action levels and clearance action levels (or lower lev- els if required by local, state or tribal authorities having jurisdiction), where the unit μg/sf means "micrograms of lead per square foot sampled" (this unit can also be written as μg/ft2):" New Dust-Lead Action Levels: • Floors: ≥ 10 μg/sf • Window Sills: ≥ 100 μg/sf New Lead Clearance Action Levels: • Interior Floors: < 10 μg/sf • Porch Floors: < 40 μg/sf • Window Sills: < 100 μg/sf • Window Troughs: < 100 μg/sf " Note that the required use of these action levels applies only to the OLHCHH's LBPHC and LHRD grants, and does not constitute rulemaking under HUD's Lead Safe Housing Rule (24 CFR 35, subparts B – R), nor apply to work conducted under that rule; nor does it apply to EPA's Lead-Based Paint Hazards rule nor their Work Practice Standards for Con- ducting Lead-Based Paint Activities rule (40 CFR §§ 745.65 and 745.227, respectively)." So…for those that have misunderstood this issue; as of right now, it's not ALL HUD work, it is for two specific grants and none of this currently applies to EPA work, i.e. LBP work that does not involve federal funding.